Compliance Safety

Should Robots Be Regulated?

Jane Alexander | February 20, 2019

How worried should you be if your co-worker is a robot?

What’s with the recent flurry of dire forecasts and associated responses regarding robots and artificial intelligence (AI)? Are productivity-driven manufacturers unknowingly putting employees at risk by placing robots on the plant floor? What type of safeguarding is required? In short, as tech executive and billionaire entrepreneur Elon Musk and others have suggested, should robots be regulated?

According to Carrie Halle of Rockford Systems, Rockford, IL (, the jury is still out. She offered the following detailed discussion of the situation and highlighted a number of relevant safety regulations and standards already on the books.


Until now, the robots used in manufacturing have primarily been “dumb” robots; that is, room-sized, programmed machinery engineered to perform repetitive tasks that are dirty, dangerous, or just plain dull. Typical applications include welding, assembly, material handling, and packaging. Although these machines are very large and certainly have enough power to cause injuries, the instances of employees actually being injured by robots are relatively rare. In fact, in the past three decades, robots have accounted for 33 workplace deaths and injuries in the United States, according to data from the Occupational Health & Safety Administration (OSHA), Washington (

So, why the sudden uproar when there are already 1.6 million industrial robots in use worldwide? Most of the calls for regulation stem from a new generation of robots called “cobots,” i.e., collaborative robots. Unlike standard industrial robots that are usually contained in cages, cobots, which incorporate near-human capabilities and traits such as sensing, dexterity, memory, and trainability, have more autonomy and freedom to move about on their own.

For cobots to be truly productive, they must work uncaged, side-by-side with people. This type of environment introduces the potential for more injuries. In the past, most injuries or deaths happened when humans who were maintaining the robots made an error or violated the safety barriers, such as by entering a cage. Many safety experts fear that, given the fact the cage is all but eliminated with cobots, injuries could rise.

Since cobots work alongside people, their manufacturers have added basic safety protections to prevent accidents. For instance, some cobots feature sensors so when a person is nearby, the cobot will slow down or stop whatever function it’s performing. Others have display screens that cue people who are nearby about what the cobot is focusing on and planning to do next. Are these measures adequate? Only time will tell.

There is another, more perilous problem with robots in general: They’re basically computers equipped with arms, legs, or wheels. As such, robots are susceptible to being hacked. But, unlike a desktop computer, a hacked robot has the ability to move about. Consider, for example, if a disgruntled ex-employee were to hack into a company’s robot and re-program to harm workers and/or destroy property. The more functionality, intelligence, and power a robot has, the greater its potential threat.


OSHA lists four types of accidents resulting from robot use in the technical manual “Industrial Robots and Robot System Safety” (Section IV: Chapter 4).

Impact or collision accidents. Unpredicted movements, component malfunctions, or unpredicted program changes related to the robot’s arm or peripheral equipment could result in contact accidents.

Crushing and trapping accidents. A worker’s limb or other body part can be trapped between a robot’s arm and other
peripheral equipment, or the individual may be physically driven into and crushed by similar equipment.

Mechanical-part accidents. The breakdown of a robot’s drive components, tooling or end-effector, peripheral equipment, or its power source is a mechanical accident. The release of parts, failure of gripper mechanism, or the failure of end-effector power tools (grinding wheels, buffing wheels, deburring tools, power screwdrivers, nut runners) are a few types of mechanical failures.

Other accidents. Other accidents can result from working with robots. Equipment that supplies robot power and control represents potential electrical and pressurized-fluid hazards. Ruptured hydraulic lines can create dangerous high-pressure cutting streams or whipping-hose hazards. Environmental accidents from arc flash, metal spatter, dust, electromagnetic, or radio-frequency interference can also occur. In addition, equipment and power cables on the floor present tripping hazards.

According to OSHA, in the past three decades, robots have accounted for 33 workplace deaths and injuries in the United States.


Robots in the workplace are generally associated with machine tools or process equipment. Since robots are machines, they must be safeguarded in ways similar to those presented for any hazardous remotely controlled machine, falling under the OSHA General Duty Clause (5)(a)(1), which requires employers to provide a safe and healthful workplace that’s free from recognized hazards likely to cause death or serious physical harm. Also applicable are OSHA 1910.212 (a)(1) “Types of Guarding” and 1910.212 (a)(3)(ii) “The point of operation of machines whose operation exposes an employee to injury shall be guarded.”

Various techniques are available to prevent employee exposure to robot hazards. The most common technique is to install perimeter guarding with interlocked gates. A critical parameter relates to the manner in which the interlocks function. Of major concern is whether the computer program, control circuit, or the primary power circuit is interrupted when an interlock is activated. The various industry standards should be investigated for guidance; however, it is generally accepted that the primary motor power that drives the robot should be interrupted by the gate interlock.

In general, OSHA’s view on robot safety is that if the employer is meeting the requirements of ANSI/RIA R15.06, Industrial Robots and Robot Systems-Safety Requirements, then the manufacturer has no issues. (For guidance on how to select and integrate safeguarding into robot systems, refer to Robotic Industries Association’s Technical Report: RIA TR R15.06-2014 for Industrial Robots and Robot Systems–Safety Requirements and Safeguarding.)

Published by the American National Standards Institute (ANSI), Washington (, and the Robotics Industry Association (RIA), Ann Arbor, MI (, ANSI/RIA R15.06 are consensus standards to provide guidance on the proper use of safety features embedded into robots, as well as how to safely integrate robots into factories and work areas. The latest revision of the standard (ANSI/RIA R15.06-2012) references, for the first time, ISO 10218-1 & 2 to make it compliant with international standards already in place in Europe. Part 1 of ISO 10218 details the robot itself; Part 2 addresses the responsibilities of the integrator.

There are also new requirements in ANSI/RIA R15.06-2012 for collaborative robots, i.e., ISO 10218 and the ISO/TS 15066 Technical Specification. This standard clarifies the four types of collaboration: Safety Monitored Stop, Hand Guiding, Speed & Separation Monitoring, and Power & Force Limiting. ISO/TS 15066 holds key information including guidance on maximum allowable speeds and minimum protective distances, along with a formula for establishing the protective separation distance and data to verify threshold limit values for power and force limiting to prevent pain or discomfort on the part of the operator.

The requirement for risk assessments is one of the biggest changes in the new RIA standard. The integrator, or end users, if they are performing the job of an integrator, now must conduct a risk assessment of each robotic system and summarize ways to mitigate any risks. This may involve procedures and training, incorporating required machine safeguarding, and basic safety management. Risk assessments calculate the potential severity of an injury, the operator’s exposure to the hazard, and the difficulty in avoiding the hazard to arrive at a specific risk level ranging from negligible to very high.

In the future, as cobot use expands, regulation of the technology will grow more focused and specific. Although cobots currently represent only 3% of all industrial robots sold, they’re projected to account for 34% of industrial robots sold by 2025, a market that itself is set to triple in size and dollar volume over that period.


According to Carrie Halle, the next 10 years will be pivotal for American manufacturing, and success largely depends on companies’ ability to navigate the transition from traditional manufacturing to IIoT-style automation and widespread use of robots. While few people have as dim a view as Elon Musk on the subject, it’s crucial that issues of employee safety not be lost in the excitement as operations shepherd robots out of their cages to work ever more closely with humans. EP

Carrie Halle is a vice president at Rockford Systems LLC, Rockford, IL. For more information, visit



Jane Alexander

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